Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Seeking waiver of penalty as provided under the Karasamadhana Scheme, 2021 - The contention urged by the respondents that waiver of penalty levied upon the petitioner under Section 70(2) in the reassessment orders dated 24.09.2020 and 27.04.2021 do not come within the scope and ambit of the scheme since Section 70(2) does not find a place in Clause No.3 of the scheme is concerned, the said contention is clearly erroneous in as much as the said penalty is undisputedly in relation to reassessment proceedings, which were completed on 24.09.2020 and 27.04.2021 much prior to the cut off date dated 21.07.2021 as contemplated in Clause 2 of the Scheme - HC
Seeking waiver of penalty as provided under the Karasamadhana Scheme, 2021 - The contention urged by the respondents that waiver of penalty levied upon the petitioner under Section 70(2) in the reassessment orders dated 24.09.2020 and 27.04.2021 do not come within the scope and ambit of the scheme since Section 70(2) does not find a place in Clause No.3 of the scheme is concerned, the said contention is clearly erroneous in as much as the said penalty is undisputedly in relation to reassessment proceedings, which were completed on 24.09.2020 and 27.04.2021 much prior to the cut off date dated 21.07.2021 as contemplated in Clause 2 of the Scheme - HC
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